Document yLdoabwO3MM91e01xEKnNmLD

BM 2035 BM 3303 BM 4019 BM 5021 BM 5089 BM 5176 BM 5304 BM 5333 BM 5393 BM 5441 BM 5645 BM 6950 BM 7020 BM 7332 BM 7920 BM 8900 BM 2085 BM 3479 BM 4025 BM 5023 BM 5105 BM 5250 BM 5306 BM 5335 BM 5398 BM 5490 BM 5715 BM 6960 BM 7021 BM 7333 BM 7950 BM 15060 BM 2156 BM 3700 BM 4123 BM 5050 BM 5118 BM 5261 BM 5310 BM 5353 BM 5418 BM 5493 BM 5809 BM 7000 BM 7025 BM 7335 BM 8335 BM 2200 BM 4011 BM 4127 BM 5075 BM 5138 BM 5280 BM 5314 BM 5367 BM 5430 BM 5498 BM 5867 BM 7009 BM 7026 BM 7410 BM 8450 BM 2819 BM 4018 BM 5020 BM 5084 BM 5144 BM 5303 BM 5315 BM 5383 BM 5440 BM 5505 BM 6935 BM 7017 BM 7315 BM 7732 BM 8718 INTERROGATORY NO. 20: With respect to each asbestos-containing product listed for each subpart of Interrogatory No. 19: (a) Identify the specific company (Defendant, predecessor, related company) which designed, manufactured, processed, specified, sold, distributed, applied, installed, patented or re-labeled such product; (b) State the year in which Defendant, its related company or its predecessor first designed, manufactured, processed, specified, sold, distributed, applied, installed, patented or re-labeled such product; and, (c) State the year in which the Defendant, its related company or predecessor last designed, manufactured, processed, specified, sold, distributed, applied, installed, patented or re-labeled such product. RESPONSE: See General Objections Nos. 1-8. Union Carbide further objects to this Interrogatoiy on the ground that it is overly broad. Subject to its objections. Union Carbide responds as follows: Calidria is a unique short-fiber chrysotile asbestos uncontaminated by tremolite, which Union Carbide extracted from an asbestos ore deposit in the New Idria area of San Benito County in California which was discovered in 1957. The mining was performed by a small number of employees and sub-contractors and was carried out every year or every other year, depending on the circumstances, during the period May to October. The ore deposit was mined by conventional open pit methods. The Calidria asbestos that was mined was stored until processed at Union Carbide's plant located near King City, California. The following divisions or subsidiaries of Union Carbide operated the Calidria business DOCSNYI:IOI2018.I 16